Marine Atlantic Inc. Accessibility Plan 2023-2025

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Marine Atlantic Inc.
Accessibility Plan 2023-2025

                               Submitted December 2022
Accessibility Plan 2023-2025

                                                           Table of Contents
General........................................................................................................................................................... 3
   Executive Summary ................................................................................................................................... 3
   Feedback and Alternative Formats ............................................................................................................ 3
Key Areas ....................................................................................................................................................... 4
   The Built Environment ............................................................................................................................... 4
       Actions, Timelines, and Responsibilities ................................................................................................ 5
   Design and Delivery of Programs and Services ......................................................................................... 6
       Actions, Timelines, and Responsibilities ................................................................................................ 9
   Communication, Other Than ICT ............................................................................................................... 9
       Actions, Timelines, and Responsibilities ................................................................................................ 9
   Information and communication technologies (ICT) ...............................................................................10
       Actions, Timelines, and Responsibilities ..............................................................................................12
   Transportation .........................................................................................................................................12
       Actions, Timelines, and Responsibilities ..............................................................................................12
   Employment.............................................................................................................................................12
       Actions, Timelines, and Responsibilities ..............................................................................................14
   Procurement of Goods, Services, and Facilities ......................................................................................14
       Actions, Timelines, and Responsibilities ..............................................................................................15
   Training ....................................................................................................................................................15
       Actions, Timelines, and Responsibilities ..............................................................................................15
   Provision of CTA Accessibility-Related Regulations.................................................................................16
Consultations ...............................................................................................................................................16
Summary of Action Items ............................................................................................................................17
Glossary........................................................................................................................................................19

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                                               General

Executive Summary
Marine Atlantic is a federal Crown Corporation tasked with fulfilling the constitutional mandate of
offering freight and passenger ferry service between Port aux Basques, Newfoundland and Labrador
(NL), and North Sydney, Nova Scotia (NS). The Corporation also offers a non-constitutional seasonal
service to Argentia, Newfoundland and Labrador. Marine Atlantic’s service is vital to connecting the
Province of Newfoundland and Labrador with the rest of Canada. The organization is guided by the
corporate vision of being an essential, progressive transportation system that people trust to deliver, as
well as the corporation’s values of safety, teamwork, diversity, integrity, excellence, and commitment.

Preventing and removing barriers for both its customers and employees is important to Marine Atlantic,
with the Corporation striving to create an environment in which everyone is treated with dignity and can
fully participate. As a transportation service provider, the Corporation’s goal is to provide a positive,
accessible transportation experience for persons with a disability regardless of physical or sensory
impairments. Marine Atlantic’s leadership continues to include objectives to support accessibility,
diversity, and inclusion in the annual strategic plans for the organization, highlighting their ongoing
value to the organization.

Marine Atlantic takes seriously the responsibility to remove barriers to travel for persons with
disabilities and is proud of the achievements to date. The Corporation will continue working to remove
additional barriers and make the organization and its services even more accessible into the future.

Feedback and Alternative Formats
Marine Atlantic welcomes feedback on any accessibility-related items. The Manager of Customer
Relationships is the designated contact to receive accessibility feedback on behalf of the Corporation
and informs and involves other departments as required by the content of the feedback.

Contact:

                                   Phone    1-800-341-7981

                           Relay services   SRVS Canada VRS
                                            Dial 9050 within the app
                                            support@SRVSCanadaVRS.ca

                                      TTY   1-877-820-9252

                                    Email customerrelations@marineatlantic.ca

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                                   Address    Marine Atlantic Inc.
                                              10 Fort William Place, Suite 302
                                              Baine Johnston Centre
                                              St. John's, NL
                                              A1C 1K4

This plan is also available in alternative formats: print, large print, braille, audio format, and an
electronic format. Requests for one of these alternative formats, or the submission of feedback, may be
made through the contact information above or through any of the Corporation’s social media channels
which include Facebook, Twitter, LinkedIn, Instagram, and YouTube.

                                               Key Areas

The Built Environment
Accessible facilities are a key component of Marine Atlantic’s operational infrastructure and vital to
supporting the achievement of its mandate. The Corporation operates four vessels and three terminals,
as well as various administration office spaces.

Terminals are maintained in Port aux Basques, NL, and North Sydney, NS, with a seasonal terminal
operated in Argentia, NL. Each terminal has accessible parking, entrances and washrooms, signage that
includes tactile and/or braille where applicable, as well as elevators where occupied spaces are on more
than one level. At terminals where the curbside area cannot be seen by staff, a video intercom system is
available to allow persons who require assistance to contact staff inside the buildings. Service dog relief
areas are established in both the secure and non-secure areas at each terminal along with associated
directional signage. There is accessible parking at terminals for visitors, employees and travelling
passengers that links to accessible paths to terminal buildings.

In addition to its terminal facilities, Marine Atlantic leases corporate office space in St. John’s, NL, that
includes elevators, as well as accessible parking, entrances, and washrooms. In North Sydney, NS, the
corporation has an administration building as well as two operations buildings, all of which are owned
by Marine Atlantic. Accessible parking is available at all locations. One of the operational buildings, an
older structure, is not accessible, while the other two facilities have accessible entrances and
washrooms, and elevators where multiple levels exist.

Currently, the Corporation rents or owns a variety of administrative and operational facilities in Port aux
Basques, NL. The accessibility features of these locations vary, with some barriers existing at older
buildings. A multi-year project began in 2021 to construct a new administration building to address

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current space and infrastructure challenges and consolidate administrative functions currently located
at several of these locations. Working with design professionals, Marine Atlantic ensures that applicable
accessibility code requirements are implemented in a manner that supports and enhances physical,
social, and psychological barrier-free design to improve accessibility, inclusion, and equity for all.

Marine Atlantic’s current vessels include the MV Highlanders, the MV Blue Puttees, and the MV Leif
Ericson, which are owned and operated by the Corporation, as well as the MV Atlantic Vision, which is
leased. All vessels are maintained to strict regulatory and safety standards and must comply with
Transport Canada Marine Safety Statutes and Regulations. They are inspected by Transport Canada
Marine Safety and DNV, a world-leading classification society, to ensure compliance with these
regulations and codes. The Safety Management System of the vessels is audited independently by Class
Society, Lloyd’s Register, to verify compliance with the requirements of the International Safety
Management Code for the Safe Operations of Ships and Pollution Prevention.

Each vessel has various accessibility features including elevators, signage that includes tactile and/or
braille where applicable, service dog relief areas, accessible public washrooms, and adapted cabins and
seating. Both mobility and hearing adapted cabins are available and each type has specific features, such
as a washroom and shower that can accommodate mobility aids and visual doorbells respectively.

Marine Atlantic has entered into a 5-year charter agreement with Stena North Sea Ltd. to supply a new
Ro-Pax vessel for the fleet. Following the charter agreement, Marine Atlantic will have an option to
purchase the vessel. The ice-classed vessel will be approximately 200 metres in length and carry up to
1,000 passengers, along with commercial and passenger vehicles. It will incorporate the latest
accessibility standards, energy efficient green ship technology, and enhanced maneuvering ability. The
ship will be compatible for use on both the Port aux Basques and Argentia services and is expected to
enter service in the 2024-25 fiscal year.

Barriers in Marine Atlantic’s built environment are largely related to older infrastructure that was
constructed or procured prior to the existence of current accessibility standards. As facilities are
upgraded or replaced, accessibility requirements receive significant attention. There are also some
potential barriers related to vessel safety or class requirements that cannot be changed. Efforts are
made to mitigate the impact of these requirements, often by providing assistive devices or individual
assistance

Actions, Timelines, and Responsibilities
Some accessible features in public buildings, such as automatic door openers and call buttons, are not
used on a regular basis. It is possible that potential issues with these devices may go undetected until
they are required for use. To better ensure these features are maintained in proper working order and
any issues are identified promptly so they may be rectified, a checklist of accessibility features will be
developed for each site. The Manager of Customer Relationships will oversee the development of these

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checklists by end of Fiscal Year 2022-23 and work with appropriate managers as required to have them
completed monthly.

By the end of 2024, the Manager of Maintenance will undertake a review of existing owned
administration and operations buildings to inventory existing physical barriers and begin exploring
options to improve accessibility to and within at least two of the structures. This review will provide
Marine Atlantic a clear understanding of the current state of its owned infrastructure in terms of
accessibility and allow additional planning for future improvements.

Design and Delivery of Programs and Services
Marine Atlantic operates ferry services on two routes, a year-round 96 nautical mile daily ferry service
between Port aux Basques and North Sydney and a seasonal 280 nautical mile ferry service between
Argentia and North Sydney. Marine Atlantic transports a diverse assortment of traffic daily, including
passengers, passenger vehicles, tractor trailers and their drivers, drop trailers, and many others. From
shipping large volumes of freight to offering modern passenger amenities, Marine Atlantic strives to
provide a safe, reliable, and quality travel experience that is accessible for all.

Marine Atlantic is governed by various acts and regulations including the Canada Labour Code,
Transportation of Dangerous Goods Act and Regulations, International Maritime Dangerous Goods
Code, Marine Liability Act and Regulations, Canada Shipping Act and Regulations, Financial
Administration Act, Domestic Ferries Security Regulations, and Sulphur Emission Control Areas
Regulations.

The Corporation has two committees, the passenger focused Accessibility and Inclusion Advisory
Committee and the internally focused Equity, Diversity, Accessibility, and Inclusion Advisory Committee.
The mandate of both groups is to grow relationships with internal and external stakeholders, including
members of the disability community. The committees provide insight and feedback on Marine
Atlantic’s current programs, services, and accessibility approaches, helping to identify potential areas for
improvement to the benefit of employees and customers. Cross-committee participation and multi-
functional representation in these groups provides for communication flow, consistency of training and
activities, and better outcomes overall.

The Marine Atlantic Accessibility and Inclusion Advisory Committee will participate in consultative
processes in relation to various regulations and requirements, especially those relating to the
Corporation as a transportation service provider, including this Accessibility Plan.

Transportation Services
Marine Atlantic has long been committed to providing all customers with a comfortable and enjoyable
journey regardless of any physical or sensory impairment. Over the years, the corporation has
incorporated accessibility into its services so that all customers are treated equitably, and it continues to
look for new and innovative ways to provide a barrier-free service as much as possible. Post-travel

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customer satisfaction surveys are conducted regularly, and passenger feedback is reviewed for potential
improvement ideas, including accessibility services.

At all points during the journey, staff members are available to provide assistance. Passengers are asked
to advise Marine Atlantic of any assistance or accessible services they may need when making their
booking. They are asked to provide a minimum of 48 hours notice; however, efforts are made to provide
services even when advance notice is not supplied.

Once accessibility-related services or assistance is requested and confirmed for a passenger, details are
added as additional resources on their booking and show on their travel itinerary. Employees at
terminals will also add these resources if requests are made at check-in. Available resources include:
                •   Requires accessible parking
                •   Travelling with support person
                •   Travelling with service dog
                •   Travelling with emotional support animal
                •   Assistance with boarding/disembarkation
                •   Reserved accessible accommodations
                •   Requires individual safety briefing
                •   Requires assistance during travel
                •   Requires assistance with baggage
                •   Requires extra space
                •   Requires terminal wheelchair
                •   Requires vessel wheelchair
                •   Notification of severe allergy

Both service dogs and emotional support animals are accepted for travel and documentation is
requested for both types of animals. Approved service dogs that are leashed or harnessed may
accompany passengers to all public places on shore and on board. Passengers are asked to submit
documentation in advance of travel that is issued by an organization or person specializing in service dog
training. Documentation must identify the person with a disability and show that the service dog has
been individually trained to perform a task to assist them with a need related to their disability.
Documentation from online, paid certification sites that do not include animal training is not accepted. If
a dog’s certification cannot be verified, the areas it can visit may be restricted.

Marine Atlantic recognizes emotional support animals (ESAs) are different than certified service dogs;
they provide support through their presence and may be trained or untrained. To travel with a support
animal, passengers must submit documentation from a medical doctor or licensed mental health
professional that includes the passenger’s name; verifies their requirement to have the animal with
them during travel; is dated within 36 months from the intended travel date; includes the professional’s
type of license and their full contact information; and is signed by the medical professional. Passengers

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travelling with a support animal must book cabin accommodations, where the animal must remain for
the duration of travel. Support animals are not permitted in public areas that are not pet friendly.

Marine Atlantic requests documentation for some accessibility-related requests including travelling with
support persons or service and support animals to verify and facilitate the service. Documentation can
be provided and approved in advance via physical or electronic means to provide certainty during travel.
Upon the request of a customer, documentation can be kept on file for up to three years for use during
subsequent travel. Exceptions are considered on a case-by-case basis.

Preboarding for reserved passengers with disabilities is available upon request as is assistance through
all parts of the check-in and security screening process. Passengers can maintain the possession and use
of their mobility aids at all points during their journey, meaning there is no time that a mobility aid must
be disassembled or packaged. Wheelchairs are available for customer use onboard all vessels and in
terminals. Extra space is available for service dogs or mobility aids in general lounge areas at terminals
and onboard vessels. On occasion, employees also make use of the transportation service for work and
personal reasons and may avail of the same accessibility features and services available to all customers.

Employee Services
Employees are widely dispersed both geographically and chronologically given the nature of a 24-hours-
a-day, 365-days-a-year service operating in multiple locations, including on board working vessels. The
Corporation’s Diversity and Inclusion Action Plan includes the objectives of creating a workplace which is
fair, safe, and inclusive of persons with disabilities. The plan also includes strategies to foster diversity
and inclusion in our workforce, helping us make positive contributions to social inclusion and workforce
participation.

Delivery of programs to employees, including employment information, training, employee support
programs, job information, etc., takes many forms including in-person, virtual connections, print items,
and various electronic means. Support and alternatives are provided on an as-needed basis to
employees accessing any program or service. Marine Atlantic provides all employees with an Employee
Family Assistance Program, a confidential support service that can help employees and their family with
a wide range of challenges relating to physical/mental health, wellness, diversity and much more, at no
cost to employees.

Marine Atlantic regularly highlights and celebrates accessibility-related events in its employee
newsletter and through organized events to help educate employees on the subject and show the
commitment of the organization toward accessibility.

Work is also ongoing to further develop and implement Marine Atlantic’s Equity, Diversity, Accessibility,
and Inclusion strategy. A vision, mission and objectives were developed from an engagement process
that included employees and external organizations, and following this, division specific action plans and
evaluation processes are being developed. These initiatives are regularly monitored and reported to the
Executive and the Board of Directors.

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Actions, Timelines, and Responsibilities
The Manager of Customer Relationships and the Organizational Effectiveness Specialist will coordinate
on a plan to survey employee engagement with accessibility topics, both as it relates to their job duties
and their own employment. Consideration will also be given to the possible inclusion of select external
resources such as vendors and consultants who also perform work for Marine Atlantic. A draft proposal
for a survey will be developed by the end of 2023 and submitted for budgetary consideration for the
following fiscal year. A formal survey will provide first-hand information about real or perceived barriers
faced by employees, and those they see as the front-line providers of service to customers, allowing
action to be taken to remove or lessen those barriers. It will also provide key metrics to allow ongoing
measurement of progress on accessibility issues from an employee perspective.

Communication, Other Than ICT
Communication to internal and external audiences is carried out in many ways depending on the
purpose and circumstances with the overall goal of providing the information in a manner that is most
useful to the intended recipients.

Marine Atlantic’s accessibility awareness training helps educate employees about ways to communicate
that considers the needs of the person they are communicating with, such as clear, concise, and plain
language, gestures, large print, writing, or various other means including electronic options. Employees
are educated on the importance of seeking information from the person about their preferred method
of assistance, whether that is alternative forms of communication or any other type of assistance that
may be required.

When offering various services to passengers, staff are prepared with alternatives that provide
accessible options. For example, the safety video that is shown at the start of each crossing is closed
captioned. Each vessel also has an iPad which allows the passenger to watch, pause and play the video
and adjust the volume. A large text print version of the dialogue is also available upon request in either
print or electronic format. Crew members can also provide an in-person, individual safety briefing upon
request to ensure all important safety information is communicated and questions addressed.

Customers making reservations for travel are engaged about their needs in relation to their disability
once they self-identify to a reservations agent. Currently, customers utilizing the online booking engine
are asked to contact a reservations agent to discuss or confirm requests for accessibility services.
Improvements are under development to our online booking engine that would allow customers to
include most accessibility-related requests they may have as part of the online booking process.

Actions, Timelines, and Responsibilities
Marine Atlantic’s policy on Travel-Related Information in Multiple Formats was last updated in 2007 and
is outdated on current requirements, processes, and technologies. The Manager of Customer

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Relationships will review the policy and present the Executive with a recommendation by end of Fiscal
Year 2022-23.

Information and Communication Technologies (ICT)
Marine Atlantic utilizes numerous information and communication technologies both internally and
externally. In general, the Corporation’s telecommunication, computer and network systems use
industry standard equipment and software.

Digital signage is used for communication to employees, as well as directly to customers. Screens are
available in public and employee areas and display various messages. Currently, these screens display
visual content only and there is no alternative format available.

Onboard vessels, a television-based entertainment system is provided in public and employee areas,
including most cabin accommodations. A large capital project was completed in 2022 to upgrade the
systems on the MV Highlanders and the MV Blue Puttees. The new system provides a mix of live
television and on-demand entertainment content. In crew and passenger cabin accommodations, users
can control the choice of channel, audio options, as well as start, stop and pause playback. In main
passenger lounges, several large screens display different entertainment content. No sound is
broadcast, and passengers use earphones connected to jacks in the seats to access the sound and closed
captioning is always broadcast as a standard feature. Passengers wishing to avail of described video
options, or who wish to control the playback in other ways, can opt to view content via their own or a
loaned personal electronic device.

The current entertainment systems on the MV Atlantic Vision and MV Leif Ericson are pre-existing and
do not offer all the accessible features, such as playback controls or described video in either crew or
passenger areas. There is limited internet connectivity on board our vessels while at sea, which
eliminates streaming content to individual devices as a viable option. Marine Atlantic continues its
search for available options to provide comparable entertainment content via personal electronic
devices.

Externally focused
The Marine Atlantic websites (MarineAtlantic.ca and MarineAtlantique.ca) are routinely evaluated in
accordance with AA guidelines. New functionality is vetted against accessibility guidelines during the
requirements gathering phase of development. Additionally, the identification and resolution of
guideline issues is set forth in the Service Level Agreement with the contractor. A number of manual and
automated screenings are completed using software to establish compliance with the guidelines.
Specifically, an AA audit is completed, along with a Lighthouse Scan of the Drupal Operating System.

Social media provides an opportunity to share information and interact with customers in a manner that
best meets their needs. The Corporation’s social media presence continues to grow each year through
its Twitter, Facebook, Instagram, YouTube, and LinkedIn accounts as well as the Marine Atlantic blog.

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Whether there is a schedule advisory or other important information regarding upcoming travel,
customers with impacted reservations receive direct communications via e-mail and SMS advisories that
can be read on the users’ device of choice.

Where supplementary, or publicly available information about transportation-related services, safety or
facility is available in an electronic format, the organization has ensured that the format is compatible
with adaptive technologies. Materials are available for viewing on personal devices using the customers’
adaptive technology or available using a company loaned device for the purposes of reviewing
transportation-related information. Information provided on the company loaned device is compatible
with the Apple suite of adaptive services and Adobe text-to-speech to ensure multi-level access. The
electronic devices are configured and tested prior to being placed in service to ensure that adaptive
functionality is enabled and in working order.

Marine Atlantic provides telephone access to customers via a toll-free line, which is able to accept all
types of relay services. A TTY phone number and various email addresses are also made available for
public use.

Public announcements in terminals and onboard vessels are made using a mixture of pre-recorded and
live voice. In both cases, when making announcements employees activate flashing amber lights to
indicate to passengers that a verbal announcement is being made. Passengers can receive information
about the announcement from a staff member at the ticket counter or reception desk including in large
print. This procedure is described for passengers on the Marine Atlantic website. The text of all
announcements is made available in accessible formats such as large print or electronic format. A
project is ongoing that will see the text of announcements also be displayed on digital screens in public
terminal areas which is anticipated to be complete by October 31, 2022.

Internally focused
Marine Atlantic is committed to sharing information and educating its employees through various
channels. In addition to internal e-mail and print notices, the Corporation uses its branded mediums
such as MyPort Intranet, MyPort TV (digital signage) and MyPort Magazine, in addition to in-person
communication methods such as team meetings or one-on-one conversations. Important messages are
rarely communicated via a single medium.

Content for the MyPort Intranet site is developed with consideration of accessibility principles such as
contrast and font size. It is hosted on the SAP Jam platform and has built-in accessibility features;
however, a full review of the site has not been undertaken to date. The internal magazine is available in
print, as well as in an electronic version that supports screen reader and other adaptive technologies.

Generally, when an employee accessibility need is identified, a positional-based review of the
technologies that they may use would be completed and any gaps or accommodations addressed up to
the point of undue hardship.

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Actions, Timelines, and Responsibilities
Under the guidance of the Director of Communications, an internal review of employee facing intranet
resources will be undertaken. This work, anticipated to be completed by the end of Fiscal Year 2023-24,
will identify ways to improve the current offering of information and lead to the drafting of accessibility
guidelines for internal information distribution in future periods.

Marine Atlantic is aware of several adaptive technologies that are available to assist persons with
disabilities navigate public spaces. In 2023, the Manager of Customer Relationships will research the
options available to determine potential benefits that may be provided by the use of such technologies
in shore-based locations. A recommendation will be put forward by the end of the year to Marine
Atlantic’s executive team.

Transportation
Most Marine Atlantic passengers access the service using their own vehicles, which they drive onboard
themselves. The Corporation also provides a shuttle bus service to take foot passengers between
terminal buildings and vessels. All Marine Atlantic owned shuttle buses are accessible, featuring a
wheelchair lift in the rear of the vehicle.

Employees are generally responsible to arrange their own transportation to and from the workplace and
when travelling for business purposes. In less common instances when other types of transportation are
contracted, such as external taxi or bus services, the accessibility needs of the user group are
considered.

See also Design and delivery of programs and services for information about transportation services
provided by Marine Atlantic.

Actions, Timelines, and Responsibilities
As the Corporation renews its fleet of shuttle buses, accessibility is a key consideration. New all electric
shuttle buses are being purchased that will have improved accessibility features compared to current
models in use. These vehicles are expected to arrive by end of Fiscal Year 2022-23 and should be in
service later in 2023.

Employment
Marine Atlantic employs approximately 1,300 individuals, approximately 1,100 full-time equivalent
employees, over 90% of whom are unionized across six separate bargaining units. Marine Atlantic aims
to have a workforce reflective of the diverse communities it serves. To that end, the Corporation has
identified persons with disabilities as one of five under-represented groups as a focus for our diversity
and inclusion initiatives.

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The Corporation has several ongoing diversity and inclusion initiatives with objectives of creating a
workplace which is fair, safe, and inclusive of persons with disabilities. Strategies are being developed to
foster diversity and inclusion in our workforce, helping us make positive contributions to social inclusion
and workforce participation. Marine Atlantic also has an Employment Equity Policy, which strives to
reach equality in the workplace through a program to correct the conditions of disadvantage in
employment experienced by persons with disabilities and other underrepresented groups.

All job postings include a statement affirming our commitment to the principles of equitable
employment for all and strongly encourage applications from persons with disabilities, and other
identified groups. Applicants that identify as a member of one or more of these groups, are encouraged
to voluntarily state to which group(s) they identify in their cover letter, resume or application. As part of
its recruiting process, the Corporation continues to reach out to 46 organizations to post jobs and
advertise Career Fairs. These organizations offer employment services to clients from employment
equity designated groups to encourage submission of application for employment from their clients. The
strategic targeting of these organizations has raised the profile of Marine Atlantic as an equity employer
and helps maintain positive relationships.

Through our Employment Equity Surveys, we receive information from our employees to determine
plans and strategies to address potential barriers. This information helps us review our processes to
ensure they are fair and transparent and do not have an adverse impact on any particular group and
helps measure our progress. In 2021, Equity, Diversity, Accessibility, and Inclusion was added to the
Human Resources divisional section of the Corporation’s risk profile. This will integrate this lens in our
Corporate Risk Strategy review process.

Marine Atlantic has a dedicated Occupational Health and Wellness team within the Human Resources
Department. In addition to core responsibilities for the Disability Management Program, Early and Safe
Return to Work planning, and promoting health and wellness resources to employees, team members
are key in workplace accommodation processes. The goal of these accommodation processes is to
create and maintain a barrier-free environment and to ensure full participation for employees and
external candidates for employment by:
    • identifying and removing barriers to employment, career development and promotion of
        persons with disabilities unless doing so would result in undue hardship;
    • designing all employment systems, processes and facilities to be accessible by building
        accommodation into workplace standards, systems, processes and facilities;
    •   providing individual adjustments in the workplace that respond to the needs of a specific
        employee or candidates who may need to be accommodated under the prohibited grounds of
        discrimination of the Human Rights Act; and
    •   accommodating individuals when such barriers cannot be removed to the point of undue
        hardship taking into consideration issues of health, safety, and cost, and respecting an
        individual's right to privacy and confidentiality.

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Marine Atlantic strives to make its workplace environments diverse and inclusive where all employees
are valued, engaged, and can thrive. This goal is supported by various policies, procedures, and
initiatives, including those specifically relating to Workplace Harassment and Violence and Psychological
Health and Safety in the Workplace.

Transport Canada requires that all our vessel employees, which number over 700, have a valid Marine
Medical Examination. This medical requires that vessel employees be able bodied in order to respond to
potential emergencies. This limits the ability of the company to hire persons with disabilities for onboard
positions, but there are less restrictive regulations for shore-based positions.

The Corporation continues to implement key accessibility objectives. These include education
opportunities, employee awareness, customer awareness, policy reviews and involvement of
stakeholders from target groups in the program. As our Diversity, Inclusion, Accessibility and Equity
Strategy is developed and matures, annual action plans for key initiatives will be developed. The
strategy is part of our goal to build a comprehensive Psychological Health and Safety Workplace
Program at Marine Atlantic.

Actions, Timelines, and Responsibilities
Marine Atlantic uses national AccessAbility Week as an opportunity for activities to build awareness
within our employee groups around accessibility topics. Led by the Manager of Customer Relationships
and the Organizational Effectiveness Specialist, Marine Atlantic will increase these activities over the
coming years for both ship and shore-based employee groups. Aligning with the 2023 event, at least two
new employee-focused activities will be planned for the week.

Procurement of Goods, Services, and Facilities
Accessibility requirements for various purchases are included in the stated requirements of the good or
service provided by the departmental representative initiating the purchase.

Marine Atlantic most often uses two methods to post contracts with committed values over $50,000;
one is the federal government procurement online platform, and the other is an internal legal review
and contract process. For contracts at this level, there is a form that the initiator must sign indicating
they have considered accessibility requirements. This is a reminder to purchasers within the
organization of the need to account for accessibility considerations as part of the initial requirements for
any large purchases.

Smaller purchases are completed through a purchase order process and some employees also have
procurement credit cards, both with several levels of oversight. Accessibility considerations may be
included by the purchase initiator as part of the stated requirements for the good or service. The current
procurement process, for all but large purchases, currently depends on the initiator to remember
accessibility considerations when submitting requirements for goods and services.

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Actions, Timelines, and Responsibilities
Led by the Procurement and Strategic Sourcing Manager, Marine Atlantic will investigate the potential
to implement a form or checklist, similar to the one used for significant purchases, at other purchasing
levels to indicate that accessibility requirements are considered and addressed. This will enhance
current practices to help ensure accessibility considerations are reviewed and addressed in initial
purchase requirements for goods and services. A recommendation will be provided to purchasing
management by the end of 2023.

Training
Marine Atlantic has provided a full day of accessibility training as part of its new employee orientation
for more than a decade. Nearly 90% of our approximately 1,300 employees have completed this course,
which gives an overview of accessibility and its importance, the prevention and removal of barriers, and
provides employees with the language and the tools needed to assist customers who require assistance
while using our service. Refresher sessions are also provided to employees in customer-facing roles
every three years. The content and delivery of this training was reviewed in 2020 by the Accessibility and
Inclusion Advisory Committee whose members provide subject matter expert level feedback.

Employees at all levels in the organization are also provided with new or revised information about
accessibility requirements, services, programs, or best practices any time it becomes available. Various
means are used to communicate depending on the circumstances, including virtual training,
newsletters, email, in-person discussions with supervisors, and more. Managers and supervisors also
have access to high-level accessibility guidelines compiled to support best practices within the
organization to create working environments that respect diversity and promote accessibility, equity,
and inclusion. The information is also intended to provide guidance to managers to integrate and adapt
accessibility, diversity, equity, and inclusion principles into their specific work environments, culture,
procedures, and policies. Supporting reference material and documentation is provided to employees
through the company intranet, via the Manager of Customer Relationships or from the Organizational
Effectiveness Specialist.

Actions, Timelines, and Responsibilities
The Manager of Customer Relationships will lead a re-organization of Marine Atlantic’s accessibility
training program into a content-based modular system, with support from the organization’s training
department. A project plan, including budgets and timelines, will be created by the end of Fiscal Year
2023-24. These changes to Marine Atlantic’s internal training will allow content to be better tailored to
specific employee groups and also provide opportunity for more frequent and meaningful refresher
training using various combinations of modules as applicable.

                                                                                              Page 15 of 19
Accessibility Plan 2023-2025

Provision of CTA Accessibility-Related Regulations
As a federally regulated marine transportation service provider, Marine Atlantic is subject to the
Accessible Transportation for Persons with Disabilities Regulations from the Government of Canada,
which has the goal of removing barriers to transportation for persons with disabilities.

As the Corporation is both a carrier and a terminal operator, sections of the regulations applicable to
Marine Atlantic include: 1–25, 28, 31–35, 37–39, 42, 46, 48–61, 134–138, 140, 142–144, 153, 163/164,
178, 212–223, 225–231, 236–238, and 243. Information on the activities and services covered by these
sections has been presented in the preceding sections.

Marine Atlantic maintains an open dialogue with representatives of the CTA and participates in its
ongoing consultative processes.

                                         Consultations
Current external members of the advisory committee include representatives from CNIB, Guide Dogs of
Canada, Canadian Council of the Blind, NL Association of the Deaf, People First NS, Coalition of Persons
with Disabilities NL, Canadian Hard of Hearing Association, and Spinal Cord Injury NL.

In March 2022, the advisory committee was asked for initial feedback on the Corporation’s upcoming
accessibility plan during a regularly scheduled committee meeting. Early feedback included the
suggestion to focus on practices and processes already in place at Marine Atlantic, as well as continuing
to include input from persons with disabilities at early stages of new initiatives. Committee members
were advised additional feedback would be requested from them once a draft plan was available for
review and welcomed to contact the Manager of Customer Relationships with any additional thoughts
or suggestions.

The advisory committee was again engaged to review the draft of this plan on June 22, 2022. Copies of
the draft documents were circulated in advance of a virtual meeting where discussion took place.
Several follow-up contacts were made with all committee members, including those who were unable to
attend the meeting. Recommendations from committee members included providing additional detail
about travelling with service dogs and emotional support animals, referencing CSA standards for the
built environment as a way to go beyond meeting current building codes, considering uses for new
adaptive technologies, and ensuring that lived experience is represented in training. These suggestions
were incorporated into this document, as well as used to help inform the applicable initiatives.

                                                                                             Page 16 of 19
Summary of Action Items

                                                                                                                                       Estimated Budget
                                             Action item                                Responsible                     Timeline
                                                                                                                                         Commitment1

                        A monthly checklist of accessibility features will be
                        developed and implemented for each site to assist       Manager of Customer             End of Fiscal Year
                                                                                                                                            $325
                        in the identification and prompt repair of any          Relationships                   2022-23
                        issues.
    The built
    environment         Review existing MAI-owned administration and
                        operations buildings to inventory existing physical
                        barriers and begin exploring options to improve         Manager of Maintenance          End of 2024                 $1250
                        accessibility to and within at least two of the
                        structures.

                                                                                Manager of Customer
                        Develop a proposal for an employee engagement                                           End of 2023 for
    Programs and                                                                Relationships and the
                        survey on accessibility topics, both as it relates to                                   budgetary submission       $1,400
    services                                                                    Organizational Effectiveness
                        their job duties and their own employment.                                              the following year
                                                                                Specialist

                        Review and present a recommendation on Marine
                                                                                Manager of Customer             End of Fiscal Year
    Communication       Atlantic’s 2007 policy on Travel-Related Information                                                                $225
                                                                                Relationships                   2022-23
                        in Multiple Formats.

    Information and     Undertake an internal review of employee facing
                                                                                                                End of Fiscal Year
    communication       intranet resources to identify improvements to the      Director of Communications                                 $2,300
    technologies
                                                                                                                2023-24
                        current offering of information.

1   Figure is based on the estimated required internal effort in addition to the procurement of related goods and services.
Accessibility Plan 2023-2025

                  Investigate existing adaptive technologies available
                                                                          Manager of Customer
                  for potential use in terminals and other locations                                      End of 2023               $325
                                                                          Relationships
                  and create recommendation for review.

                  Introduce new all electric shuttle buses with                                           Coming into service in
Transportation                                                                                                                        -
                  improved accessibility features.                                                        2023

                                                                          Manager of Customer
                  Plan at least two new employee-focused activities
                                                                          Relationships and the           Aligning with the 2023
Employment        around national AccessAbility Week for both ship                                                                  $1,400
                                                                          Organizational Effectiveness    event
                  and shore-based employee groups.
                                                                          Specialist

                  Investigate the potential to implement a form or
Procurement of    checklist, similar to the one used for significant
                                                                          Procurement and Strategic
goods, services   purchases, at other purchasing levels to indicate                                       End of 2023               $425
                                                                          Sourcing Manager
and facilities    that accessibility requirements are considered and
                  addressed.

                                                                          Manager of Customer
                  Develop a project plan for the re-organization of
                                                                          Relationships, with support     End of Fiscal Year
Training          Marine Atlantic’s accessibility training program into                                                             $2,500
                                                                          from the organization’s         2023-24
                  a content-based modular system.
                                                                          training department

TOTAL                                                                                                                              $10,150

                                                                                                   Page 18 of 19
Glossary
Class Society - A ship classification society is a non-governmental organization that establishes and
             maintains technical standards for the construction and operation of ships and certify a
             vessel complies with relevant standards.

Drop trailer – the trailer portion of a commercial tractor trailer, with no attached truck.

Drupal Operating System – a content management system that provides developers and content
           creators with a base system to build flexible websites. At Marine Atlantic, Drupal acts as the
           underlying system that our digital experience platforms are built or integrated including the
           website, online booking engine, and commercial customer portal.

Estimated Budget Commitment – anticipated costs including purchases of goods and services, as well as
           estimated internal labour costs based on the anticipated time and resources required for
           the task.

Fiscal Year – Marine Atlantic operates under 12-month periods beginning April 1 of one year and ending
             March 31 of the next.

Foot passengers – passengers travelling without vehicles.

Lighthouse Scan – an open-source, automated tool for improving the quality of web pages. It can be run
            by developers and website administrators against websites to audit performance,
            accessibility, progressive web apps, and search engine optimization.

Marine Atlantic Accessibility and Inclusion Advisory Committee – a committee including both internal
           representatives from multiple departments and various external members representing
           disability and advocacy organizations from target groups.

Nautical Mile - Nautical miles are used to measure the distance traveled through the water. A nautical
            mile is slightly longer than a mile on land, equaling 1.1508 land-measured (or statute)
            miles.

Ro-Pax vessel – an abbreviation for roll-on/roll-off passenger vessel, which means a vessel that
            accommodates vehicles, which are driven on and off, as well as passengers.
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